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HomeMy WebLinkAboutDEQ - UIC Regulations11111M-100" CO Property & Facilities Department Susan C. Ross, Director 14 NW Kearney Street, Bend, OR 97701-1960 [541) 388-6594 • Fax: (541) 317-3168 www.co.deschutes or. us December 21, 2009 TO: Board of Commissioners FROM: Susan Ross, Property & Facilities Director RE: 1/6/10 WORK SESSION REGARDING LTIC PROCESS More than a year ago, the Department of Environmental Quality issued a warning letter to all public entities requiring compliance with the new UIC (Underground Injection Control) regulations. We were required to notify DEQ whether or not we had UICs and, if so, to develop a plan to inventory, permit/register, and improve/repair the UICs. Deschutes County retained Hickman Williams Associates (HWA), a local civil engineering firm that has personnel who specializes in UICs, to develop the inventory and assessment. An executive summary of Deschutes County's plan is attached. The report found that Deschutes County has 61 UICs located throughout our various facilities, and 22 UICs located in right-of-ways. This is a fairly technical report and process, and I have invited the engineer to attend the January 6 work session in order to answer questions. If anyone would like additional sections of the report, please let me know. The table of contents is included with your packet for reference. Quality Services Performed with Pride DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT TABLE OF CONTENTS Table of Contents I. Introduction 1 II. UIC Inventory and Registration 2 III. UIC Compliance 4 A. Rule Authorization 4 B. UIC WPCF Permit 6 C. RA vs. UIC WPCF Permit 7 D. UIC Closure 8 E. UIC Sediment Sampling and UIC Systems Cleaning 8 IV. UIC Assessment 10 A. Facility UIC Categories 10 B. UIC Type Based on Assessment 10 C. Recommendations for Structural and Non -Structural BMPs 13 D. Need for Additional Information 14 E. Capital Cost Estimates 15 V. Next Steps 16 A. WPCF Permit 16 B. Interim Operation and Maintenance of County Stormwater Systems 16 C. Prioritize Capital Improvement Needs D. Long Term Operational Cost Based on Permit Exhibits 1. Letter of Intent 2. Deschutes County Zoning Map 3. DEQ UIC Registration Form 4. DEQ UIC No -Exposure Form 5. Deschutes County 2 -yr TOT Map 6. Cost Comparison of Rule Authorization vs. WPCF Permit 7. DEQ UIC Pre -Closure Notification Form 8. Guidance for Sediment Sampling, UIC Cleaning and UIC Closure Appendix 1 — UIC Database & Supplemental UIC Registration Information A. UIC Registration Database Spreadsheet B. Contaminated Site Search Summary and Information C. Water Well Search Summaries and Information Appendix 2 — Site/Facility Assessments DESCHUTES COLINTY LIIC INVENTORY AND INITIAL ASSESSMENT I. Introduction HWA has been retained by Deschutes County to inventory county -owned stormwater underground injection control (UIC) systems, provide registration information for LIICs previously not registered with the DEQ, make recommendations for the most appropriate DEQ approval mechanism (authorization by OARS or individual groundwater pollution permit), make the initial WPCF permit application (if that is the recommended approval mechanism), and make recommendations to comply state and federal stormwater UIC requirements. On December 29 2009 HWA notified the Oregon Department of Environmental Quality (DEQ) of the counties intent to comply with the UIC Program requirements. A copy of the letter is included as Exhibit 1. Deschutes County is located in the geographic center of the state of Oregon on the eastern side of the Cascade Range. The county covers approximately 3,055 square miles, has a semi -arid climate and mostly well draining soils. The county is made up of four incorporated cities and a number of unincorporated communities. The cities include Bend, Redmond, La Pine and Sisters. A map of the county is included as Exhibit 2. The purpose of this report is to inventory UICs located on county owned property and roadways register UICs that are not currently registered with the DEQ; and provide an initial needs assessment with recommendations for approval of UIC systems by the DEQ. The assessment includes preliminary estimates of anticipated capital improvement needs to meet water quality goals over the next several years. This report is intended to be provided to the DEQ with the registration information and permit application. This is a living document and as more information becomes available it can be revised. UICs typically found in central Oregon include, but are not limited to, drywells, drill holes, seepage pits and drainage galleries. The county owns and operates 22 buildings at nine distinct sites (or facilities) on 38 tax lots and is responsible for maintaining approximately 830 miles of roadway. An inventory of UIC systems conducted by HWA between November 2008 and July 2009 concluded that the county has 61 LIICs located at nine different facilities' and 22 UICs in public rights-of-way in La Pine and Terrabone. One of the UICs in the La Pine right-of- way could not be confirmed as a UIC. The US Environmental Protection Agency (EPA) defines a UIC as subsurface emplacement of fluids through a bored, drilled, or dug hole whose depth is greater than the largest surface dimension; or an improved sink hole; or, a subsurface fluid distribution system. Oregon also includes sewage drain holes and septic fields larger than 2,500 gpd. A LIIC is basically any system, structure or activity that is created with the intent to discharge liquids directly into the subsurface. The UICs of interest in the inventory and assessment are Class V stormwater injection systems. Central Oregon is unique in that it has very few natural drainage courses owing to the highly permeable soil and mostly fractured basalt. Storm sewer systems are typically constructed as urbanized areas are developed to carry runoff to nearby streams, rivers or open bodies of wates. In Central Oregon constructing storm sewers in the shallow bedrock is very expensive. Here UICs have been a relatively simple and inexpensive way to dispose of stormwater on site and ill public right-of-ways. In addition to being inexpensive to install, if UICs are properly designed PT' A number of the contiguous facilities are lumped together in this report and considered as one facility. 1 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT and maintained, they have the added benefit of preventing damage caused by larger rain events associated with collecting an concentrating runoff; recharging local groundwater; maintaining better stream base flow; and, cool, and sometimes treat, stream base -flow. However, if they are not designed, installed and operated properly they have the potential to degrade groundwater resources, contribute to localized flooding and fail prematurely. The Oregon Department of Environmental Quality (DEQ) and the U.S. Environmental Protection Agency (USEPA) regulate groundwater injection wells, stormwater drywells and drill holes under the auspices of the Underground Injection Control (UIC) program. The Oregon UIC Program was developed in response to Part C of the federal Safe Drinking Water Act in order to limit and control the injection of waste fluids in a manner that protects existing groundwater quality. The DEQ implements the UIC program through OAR 340-044. Since 2000 the DEQ has required that all new and existing groundwater injection wells be inventoried (registered) and since 2001 that all new and existing injection wells either be authorized by Oregon Administrative Rule, commonly known as rule authorization (RA), or approved by individual Water Pollution Facilities Control (WPCF) to operate such systems. RA is a prescriptive set of requirements for operating and maintaining UICs in Oregon. If the RA requirements cannot be met then the UIC systems must be operated under a WPCF permit or permanently abandon. In general, to attain RA best management practices of stormwater injection systems must be instituted to protect existing ground water quality. This includes good housekeeping practices, operating systems in a manner that prevents groundwater contamination and the implementation of stormwater pretreatment prior to groundwater injection. II. UIC Inventory and Registration During the period of November 2008 to July 2009 HWA inspected nine different county -owned facilities in Bend and Redmond and public rights-of-way in the unincorporated community of Terrabone and the City of La Pine. George Kolb, Deschutes County Road Department Engineering Services Manager, identified the rights-of-way UIC locations. The facilities were inspected with the help of county staff including Teresa Rozic, Property Specialist, and Tad Walker, Building Services Manager, under the direction of Susan Ross, Director of the Property and Facilities Department. The DEQ requires that all UICs are registered with the DEQ and entered into a DEQ UIC database. Registration of each UIC requires the completion of a UIC registration form, a copy of which is included as Exhibit 3. An alternate method of registration is the completion of a single electronic database for all of the UICs. This is a preferred method of registration for a Targe site (many UICs) or for a large number of UICs at multiple sites under single ownership. Registration by database would likely be required under and area -wide UIC WPCF permit. Registration requires that each of the UICs and the site be characterized, including, but not limited to the following information: • UIC location (latitude and longitude), depth, diameter, approximate drainage area, type of drainage received, pretreatment (if any) and type. • Depth to seasonal high groundwater and distance to nearest wetland, surface water and water well; and. 2 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT • Type of facility where the UIC is located by NAICS code and the types of materials, products and wastes handled at the facility. • Existence of known soil or groundwater contamination that might be impacted through the use stormwater injection, including the nearest cleanup site within' mile of the UIC(s). • An estimate of the number of vehicle trips generated each day at the facility or over the roadway: The number of trips, is used to classify the level of risk for groundwater contamination from polluted runoff. Residential streets and small commercial parking lots with less than 1000 trips per day (500 in and 500 out) are considered to pose less risk. The DEQ requires that the number of traffic trips be estimated using the Institute of Traffic Engineer's Trip Generation Manual, 7th edition or newer. • Land use zone, source of drinking water, characterization of the subsurface geology if available, reason why UICs are being used as apposed to a public storm sewer connection. • Identify if the UIC is located in a drinking water protection area as defined by the Oregon Department of Human Services. • Completion of a No -Exposure Certificate. This certificate has a list of criteria that if not met the UICs cannot be approved under Rule Authorization. A copy of the certificate is included as Exhibit 4. Registration requires a certain level of due diligence by the applicant. During the process of registration there are a number of site characteristics that may be identified that can preclude approval by RA. This will be discussed in further detail below. HWA has prepared a spreadsheet database and included the necessary registration information to the best of our ability given the scope of work. HWA has also included in this database the information for approximately 51 UICs that were previously registered by the county or their consultants. The registration information provided by HWA is based on initial site inspections and readily available information provided by the county or found in public databases. The site inspections provided only information about the systems that could be obtained by visual assessment from the ground surface did not include any subsurface investigation. Those systems that could be readily accessed were opened and cursory measurements made. Certain assumptions may have been made about select UIC systems that could not be verified visually. A copy of the UIC database is included as Appendix 1. Private well identification was carried out by standard well log query at the Oregon Water Resources Department website (http://apps2.wrd.state.or. us/apps/gw/well_log/Default.aspx). This information is typically used as an initial estimate for depth to groundwater in addition to identifying if a well is closer than 500 feet to a UIC. If there is a suspected water well in the area that may be within 500 feet of the UIC it may be necessary to perform a visual survey or additional due diligence to ensure that a well is not within 500 feet of the UIC. For this inventory and initial assessment HWA did not perform more that the standard well log query. Where applicable, a well log query was carried out for the UICs previously registered that did not have HWA 3 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT sufficient well search information. Any recommendations for more extensive well log search can be found in the discussion of the individual site assessments in Appendix 2. The presence of contaminated soil or water and the location of the nearest environmental cleanup site was carried out by use of the Oregon DEQ Regulated Facility Profiler (http://deg12.deq.state.or.us/fp20I). This is an interactive database by which contaminated sites can be searched. This information is used to rule out any possibility of stormwater injection impacting (mobilizing) existing soil or groundwater contamination that is hydraulically down gradient from the UIC in question. Additional information may be required by the DEQ to ensure that any known contamination is not impacted by the UIC if a contaminated site is identified down gradient. A discussion of any suspected contamination that may be mobilized by the use of groundwater injection can be found in the individual site assessments found in Appendix 2. III. UIC Compliance In general stormwater UICs are allowed to operate as long as they are operated in a way that protects the highest beneficial use of groundwater. The highest beneficial use is usually drinking water (OAR 340-040-0020(3)). In addition to registration, UICs are to be approved by the DEQ under Oregon Administrative Rule, commonly referred to as rule authorization (RA), or approved by individual Water Pollution Facilities Control (WPCF) to operate such systems. If the UICs cannot be authorized by rule or approved by permit, then they must be permanently closed. Any UIC closures must be performed according to OAR 340-044-0040 and must be carried out by an Oregon registered, geologist, geotechnical engineer or professional engineer. A. Rule Authorization Rule authorization is a prescriptive set of requirements that must be met in order to continue operation (OAR 340-044). There are a number or basic requirements for RA or UIC systems, including but not limited to the following: 1. There must be no exposure of runoff to hazardous materials. None of the situations listed on the No -Exposure Certification survey may take place (Exhibit 4). 2. Groundwater injection from the UIC cannot have the potential to impact (mobilize) existing soil or groundwater contamination. 3. The UIC must have adequate separation from seasonal high groundwater. In general, the bottom of a drywell must have 10 feet of separation from seasonal high groundwater for discharge from pollutant generating surfaces (PGS) and five feet of separation for roof drain or landscape only UICs. It may be allowable for 5 feet of separation from PGS UICs if the UIC is less than 5 feet in depth. In highly fractured geology with little or no soil or natural sediments to "filter" stormwater the separation depth must be evaluated on a case by case basis and is dependent on the subsurface characteristics in the unsaturated zone below the UIC and the type of pretreatment employed. 4. There must not be other wastes, including agricultural drainage, industrial waste or sanitary wastes mixing with stormwater runoff from impervious surfaces entering the UIC. 5. The UIC must not be deeper than 100 feet. 6. UIC cannot be located in defined drinking water protection area. The Oregon Department of Human Services (ODHS)has delineated drinking water protection areas W A 4 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT for certain municipal wells. The area of concern is the 2 -year time of travel (2 -yr TOT) groundwater flow path to the municipal wel1.2 7. The UIC cannot be located within 500 feet of a water well (irrigation, domestic or public water well without a designated 2 -yr TOT). 8. Design' and operation of the UIC prevents accidental or illicit spills and temporary drain blocking is provided. (Spill Prevention, Control and Countermeasure plans). 9. There is an adequate containment barrier, infiltration media or adequate BMPs (best management practices) are in place to protect groundwater quality from runoff from pollutant generating surfaces. This may or may not apply to UICs accepting roof or landscape runoff with no other wastes. Best Management Practices (BMPs) means institutional, structural and non-structural controls designed to prevent or reduce the concentration of pollutants in storm water before discharge to the subsurface: BMPs include, but are not limited to: i) Schedules of activities, prohibitions of practices, maintenance procedures, education or other management practices to prevent or reduce the pollution of waters of the state; ii) Operational and structural source controls that minimize or prevent contaminants from entering stormwater; and iii) Pre-treatment controls that remove contaminants contained in stormwater runoff before infiltration into natural subsurface soils. Additional requirements apply to municipalities with 50 or more UICs, per OAR 340-044- 0018(3)(b) or have UICs in areas that have 1,000 or more vehicle trips per day (OAR 340- 044-0018(3)(f). Note: Right-of-way (ROW) is considered a municipal facility. The DEQ assumes that large municipal stormwater systems with 50 or more injection sites pose an increased risk to groundwater quality and public health. Therefore the DEQ may require more information to evaluate the potential impacts to groundwater quality than would be required for non -municipal systems. The additional requirements include, but are not limited to the following: 10. An evaluation of potential impacts of storm water injection on groundwater quality based on the storm water volume and quality, local geology, density of injection systems, injection system design, and drainage area land use. 11. Prepare and implement a written storm water management plan (SWMP), based on current conditions and updated routinely, that includes the following: a. Storm water system -wide assessment that includes the location and construction details of all injection systems and other storm water management controls, an evaluation of the land use and activities in all areas draining into the storm water injection systems, and an identification based on available information of areas withir 2 HWA uses the state 2 -yr TOT GIS shape files prepared by ODHS. The most recent information we received was on 7/24/09. A map showing the 2 -yr TOT shape files superimposed on the Deschutes County GIS map is included as Exhibit 5. DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT the drainage catchment where hazardous substances and toxic materials are used, handled or stored. b. System controls that include best management practices for source control and treatment, and shall include measures to prevent storm water drainage from areas where hazardous and toxic materials are used, handled or stored; a spill prevention and response plan; a maintenance plan and schedule; an employee and public education plan; and the identification of personnel or contractors responsible for implementing these plans. The maintenance plan shall specify the frequency of maintenance activities, including visual inspections and physical maintenance. c. Monitoring to evaluate the effectiveness of the best management practices in eliminating contamination prior to storm water injection into the subsurface. The monitoring plan shall use information developed in the system -wide assessment to identify representative locations and types of best management practices that will be routinely monitored and sampled. At a minimum, sampling shall be conducted twice within the first 12 months of implementation of the storm water management plan, followed by annual sampling during a representative storm event at the onset of wet weather conditions. Criteria for selection of representative storm events shall follow available guidance protocols, such as the Central Oregon Stormwater Manual. DEQ UIC program does not have a fixed "design" storm or "representative" storm event. Grab samples shall be collected at the last available sampling point prior to storm water injection into the subsurface. Sampling protocols shall follow standard quality assurance and quality control (QA/QC) procedures for environmental sampling and shall use analytical methods that achieve detection limits that are below drinking water standards or risk-based levels. Samples shall be analyzed for contaminants of concern identified in the system -wide assessment, and shall at a minimum include benzene, ethylbenzene, toluene, xylenes, benzo(a)pyrene, lead (unfiltered), total chromium (unfiltered), cadmium (unfiltered), total nitrogen and fecal coliform bacteria. These are minimum requirements and depending on the suspected risk to groundwater DEQ may require additional pollutant parameters as part of rule authorization. d. A plan for record keeping and reporting. Monitoring and sampling results shall be available for review on request. e. Annual reporting on the on the municipal storm water management plan implementation, monitoring and sampling with supporting records and laboratory documentation. The report shall also include an assessment of the effectiveness of best management practices. 12. A plan and schedule to decommission existing storm water injection systems that do not meet the basic requirements in OAR 340-044-0018(3)(a), or a permit application for those injection systems. Based on discussions with DEQ UIC Program staff and past experience with other UIC projects, all of the county UIC systems would have to be sampled per A.11.c. above on a three year cycle. That is, approximately 30 UICs would have to be sampled every year. B. UIC WPCF Permit 6 DESCHUTES COUNTY WC INVENTORY AND INITIAL ASSESSMENT When UICs cannot meet the requirements of rule authorization, they may be approved by permit. It may also be desirable to operate UICs under permit because of the operational flexibility a permit may provide and it may be less cost than RA. In any event, whether the UIC systems are approved by rule or by permit, the burden of proof is on the owner/operator of the system to prove that an injection activity does not have the potential to cause a violation of the EPA'S.primary. drinking water standards, adversely impact groundwater quality, human health or the environment. Thestate requirement is to meet Oregon's anti - degradation law. For groundwater, the discharge cannot adversely impact the naturally existing groundwater quality (ORS 468B.020, ORS 468B.025 and OAR 340-040-0020(3)). It is possible to operate most, if not all of the county's existing UIC facilities under an area - wide stormwater UIC WPCF permit. However it will require meeting most of the requirements of rule authorization. It is anticipated that under permit the following RA elements will still apply: Al through A5 above would not be allowed; A6 and A7 may be allowed but additional restrictions may be imposed by. the DEQ, such as additional. characterization of potential impacts to groundwater quality and/or additional BMPs than might otherwise be required to protect groundwater; A8 through All would be required; and Al2 would be required for those UIC systems that cannot meet the requirements of the permit. Based on discussions with DEQ Program staff there is reason to believe that some of the flexibility a permit would provide is less sampling of systems that have adequate BMPs in place. For example, low risk sites meeting all of the requirements of rule authorization, including servicing of pretreatment systems and vacuuming of parking lots, may not require verification via end of pipe stormwater sampling. Sampling and monitoring requirements will be based on risk to impact groundwater. The DEQ is presently working on a UIC WPCF permit template for private and municipal UIC systems. At present only the City of Portland has an approved UIC WPCF permit. The permit is to operate over 9,000 UICs. This report, including the registration and initial assessment is the first step towards meeting requirements for an area -wide UIC WPCF Permit. C. RA vs. UIC WPCF Permit As discussed above, with a permit the state has the flexibility to look at each site or individual UIC independently of the prescriptive UIC rule authorization requirements. The most significant impact rule authorization imposes on municipalities with over 50 UICs is the requirement to test runoff to all UICs. Sites that are classified as 'moderate risk to groundwater' are not required to do annual testing under rule authorization, unless the owner of the site has 50 or more UICs. Additionally, any UICs in right-of-way with traffic volume of over 1,000 trips per day must sample regardless of the number of UICs. HWA would request that under permit the individual sites might be looked at independently and for each one to be managed based on level of risk for groundwater contamination. If, as HWA believes, the sampling requirement could be reduced there could be substantial savings to the county. Sampling of runoff and reporting to the DEQ the results of the analysis can run over $1,000 per UIC sampled. HWA has prepared an analysis of cost for RA vs. UIC WPCF permit fees and included it as Exhibit 6. The analysis assumes that the 7 DESCHUTES COUNTY I.IIC INVENTORY AND INITIAL ASSESSMENT annual DEQ fees will increase at a rate of 8% per year. The analysis shows that the cost savings in DEQ fees alone is substantial, not including the annual testing and reporting which would be more than $30,000 in the first year under RA. In a recent telephone conversation with the DEQ UIC Program director Rodney Weick (6/30/09), he stated that the county has to either apply for RA or make a permit application soon. He said that given the number of UICs it would be in the county's best interest to apply for permit. The draft permit template is expected for public review in approximately three months. If the county applies for a permit then ata later date it has the option to be refunded permit fees and apply for RA of individual UICs if the withdrawal is prior to an individual permit being drafted for the county. Based on the initial cost estimates, discussions with DEQ UIC Program staff, and the expected flexibility it is recommended that the county apply for a WPCF Permit. In December 2009 HWA notified the DEQ in writing that HWA was conducting an inventory of county UICs, providing additional registration information and would likely be applying for a WPCF Permit following the completion of the inventory and assessment and the release of the draft UIC WPCF Permit for review. At that time it was expected that a permit template would be released for public review and comment in March of 2009. D. UIC Closure When a UIC system cannot be approved by RA or by Permit is must be permanently closed and an alternate, non-UIC stormwater system must be installed (or the UIC must be relocated to an area where it could be approved if possible). UIC closure must be done in accordance with OAR 340-044-0040. The DEQ must be notified via a Pre -Closure Notification form, along with a $100 fee. DEQ policy requires a UIC sediment, sampling, cleaning and closure plan for review and approval. A copy of the DEQ Pre -Closure Notification form and Guidance for Sediment Sampling, Cleaning and Closure is included as Exhibit 7 and Exhibit 8, respectively. The guidance document is for the closure of drill holes and drywells in a parking lot or right-of-way where there is little concern for presence of hazardous materials or high levels of diesel, gas or oil contamination (no more than would be expected in typical stormwater runoff). Where there is documented soil or groundwater contamination, a history of hazardous materials use, heavy equipment use or maintenance, fuel or oil handling, etc., then the DEQ may require additional screening for potential contamination prior to closure. In accordance with OAR 340-044-0040(3)(b) an Oregon registered geologist, engineering geologist, or professional engineer must submit a signed closure report documenting that the UIC was properly closed, typically in accordance with the DEQ approved closure plan. E. LIIC Sediment Sampling and UIC Systems Cleaning The DEQ typically requires that UIC sediments be sampled for contamination and that the UIC be cleaned prior to closure or installing pretreatment BMPs. A qualified environmental services provider should carry out sampling, testing and cleaning of UICs. Guidance for stormwater system sediment sampling is included in Exhibit 8. HWA 8 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT Cleaning of UICs and any catch basins or pretreatment BMPs should be done on an as needed basis. Catch basins used prior to UIC injection should be inspected bi-annually and sediments should be removed when the depth exceeds more than 6 inches to protect UICs. Typically catch basins need to be cleaned every one to two years. Many of the catch basins and UIC systems are not cleaned regularly or may never have been cleaned and some may not be functioning. When observed during inspection, systems in severe need of cleaning have been identified in the individual site assessments in Appendix 2. Inspecting and cleaning of UIC systems, catch basins and other pretreatment BMPs is beyond the scope of this report. Any sediments and liquids removed from stormwater collection and disposal systems, including catch basins and pretreatment systems must be disposed properly at a landfill or other DEQ approved method. A DEQ licensed contractor should remove the sediments with a vac -truck. The liquids should be disposed at licensed liquid receiving.. facility or evaporated at a licensed facility and the sediments mixed with sawdust and allowed to further dry. Sediments need to be analyzed for the 8 RCRA metals and for petroleum hydrocarbons (TPH-Dx) prior to acceptance at landfill. Knott and Crook County landfills will not accept the sediments without certification as non -hazardous waste. The sediments, if non -hazardous and free of organic materials may be used appropriately as construction material. The risk of soil contamination and need for site remediation associated with UIC use is low for most commercial and industrial sites. Should the sediments be deemed hazardous based on exceeding the EPA RCRA TCLP MCLs3 for leaching of metals or the hydrocarbons exceed risk based health standards it is likely that the contamination is isolated to sediments contained in the UIC. In that case simply removing the sediments and pressure washing the UIC would suffice. However, when sediments are found to be hazardous and the there is a cleanup action occurring, there are or have been floor drains connected to the UICs, there is history or evidence of indiscriminate handling of hazardous materials, or there is warranted concern for illicit dumping then the DEQ UIC Program may refer the UIC to the DEQ Cleanup Program for further investigation. Stormwater systems must be maintained if they are to function properly. The lack of proper operation and maintenance is the leading cause of failure for stormwater collection, treatment and disposal systems. HWA recommends that a plan be developed for assessing the operation and maintenance needs of county stormwater collection, treatment and disposal systems, including non-UIC stormwater systems, as soon as possible. 3 EPA Resource, Conservation and Recovery Act (RCRA) maximum contaminant levels (MCLs) for leaching of metals based on the toxicity characteristic leaching potential (TCLP). Toxic Characteristic Leaching Procedure (TCLP) is an EPA SW -846 analytical method (Method 1311) that simulates sanitary landfill contaminant leaching in waste samples. Based upon concentrations of the TCLP constituents and guidelines set forth in 40 CFR 261.4, the solid waste samples can be deemed hazardous or non- hazardous for sanitary landfill disposal purposes. The recommended alternative to the TCLP test is a Total Metals test method, which less expensive and inferences can be made as to exceeding the TCLP MCLs. Should the Total Metals test infer the possibility of exceeding the TCLP the TCLP test could be conducted on the metal(s) of concern. Additionally, the SPLP method (EPA's synthetic rain test) can be used to determine if there was a potential for UIC contaminants leaching to groundwater. Rain water is less acidic than the TCLP method. Therefore there is a lower leachability risk. H DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT IV. IIIC Assessment In addition to the inventory of UICs, HWA has made an initial assessment of existing UIC systems. The assessment of individual UIC systems prepared by HWA is based initial site inspections and readily available information provided by the county or found in public databases. The site inspections did not include any subsurface investigation and only included information about the systems that could be obtained by visual assessment from the ground surface. Those systems that could be readily accessed were opened, visually inspected and qualitative and quantitative data was gathered. Certain assumptions may have been made about select UIC systems that could not be verified visually. The individual site UIC assessments are included in Appendix 2. A. Facility UIC Categories The DEQ has three UIC types used for determining fees for registration under rule authorization. For the purposes of this report HWA has chosen to use these types as categories for classifying the level of risk the accessed site/facilities poses to groundwater contamination. Table 1 below includes the three categories and the types of UICs in those categories. For the purposes of the UIC system assessments the site/facility will be included in one of these three categories, where applicable, with the exception of 3b and 3c. B. UIC Type Based on Assessment For the purposes of assessing the county UIC systems we have ranked the UICs as Type A, B, C, D or E. Table 2 below includes the UIC Type and general definition of each type. In HWAs estimation, Type A and B UICs are considered compliant and Type C and D UICs are non-compliant, with regard to adequate pretreatment BMPs. Type E UICs will have to be closed and replaced with non-UIC stormwater systems. FIWA 10 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT TABLE 1: DEQ UIC Categories for Rule Authorized UIC Systems CATEGORY 1. LEAST ENVIRONMENTAL RISK TO GROUNDWATER a. Common roof drains (Residential, Commercial, Industrial); Roof drainage injection system not mixed with any other type of discharge Note: Roof drainage injection system mixed with any other type become that type risk (box 2, below). CATEGORY 2. MODERATE ENVIRONMENTAL RISK TO GROUNDWATER a. Mixed roof/parking lot injection systems Example: Roof drained mixed with driveway, parking lot, alley, or road runoff. b. Small jurisdictions owning a total of fewer than 50 injection systems c. Owners with fewer than 50 injection systems (at one site or multiple locations) d. Owners who do not store, handle, or use hazardous materials, toxics, or petroleum products e. Sites that generate fewer than 1,000 trips per day (for contiguous Tots or acreage under one owner) f. Small/medium parking lots, residential roads CATEGORY 3. SIGNIFICANT POTENTIAL FOR ENVIRONMENTAL RISK a. Complex sites with significant potential for environmental risk b. Owners of sites generating 1000 or more trips per day (ITE manual calculation) on all contiguous lots c. Owners of sites with hazardous materials (storage, handling, generation or use), toxics, or petroleum products d. Loading docks e. Roof drain mixed with large parking lot drainage f. Any site where monitoring is required 11 DESCHUTES COUNTY UIC INVENTORY AND INI'T'IAL ASSESSMENT TABLE 2: Assessed UIC T • e TYPE A (compliant, will meet RA) UIC system will meet LIIC rule authorization requirements for the specified DEQ UIC Category (see Table 1 above) without significant physical improvements to the UIC system. • NI of the basic requirements for RA have been met, including structural BMPs. • Will require use of non-structural BMPs through the implementation of a DEQ approved (SWMP). Note, site may have an approved SWMP but may not be actively im •lementin • it. TYPE B (compliant, will require WPCF Permit) UIC system will not meet RA requirements but is likely to meet groundwater protection requirements under permit without significant physical improvements to the UIC system. • Will require use of non-structural BMPs through the implementation of a DEQ approved (SWMP). Note, site may have an approved SWMP but may not be actively implementing it. • Under permit, additional structural and non-structural BMPs may be required for Category 2 and Category 3 UICs located in a DWPA, 2 -yr TOT or within 500 feet of water well. TYPE C (non-compliant, will meet RA with improvements) UIC system will meet UIC rule authorization requirements for the specified DEQ UIC Category (see Table 1 above) with physical improvements to the UIC system (pretreatment BMPs) or isolation of loading dock(s). • All of the basic requirements for RA have been met, not including structural BMPs. • Will require the implementation of structural BMPs for pretreatment of stormwater. • Will require use of non-structural BMPs through the implementation of a DEQ approved (SWMP). Note, site may have an approved SWMP but may not be actively im •lementin • it. TYPE D (non-compliant, will require WPCF Permit with improvements) UIC system will likely to meet groundwater protection requirements under permit with physical improvements to the UIC system (pretreatment BMPs) or isolation of loading dock(s). • Will require the implementation of structural BMPs for pretreatment of stormwater. • Will require use of non-structural BMPs through the implementation of a DEQ approved (SWNIP). Note, site may have an approved SWMP but may not be actively implementing it. • Under permit, additional structural and non-structural BMPs may be required for Category 2 and Category 3 UICs located in a DWPA, 2 -yr TOT or within 500 feet of a water well. TYPE E (non-compliant, must be closedlreplaced) UIC systems cannot be approved and will have to be decommissioned and replaced with non- UIC stormwater systems. A 12 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT C. Recommendations for Structural and Non -Structural BMPs The Federal Safe Drinking Water Act is a numeric compliance based act and the EPA has established numeric based criteria for compliance with underground injection. The criteria include meeting federal drinking water Maximum Contaminant Levels (MCLs) and human health based standards. Therefore, under permit it may be possible to operate UIC systems without any form of pretreatment and still protect groundwater quality, however, the DEQ will require verification through runoff monitoring. Runoff monitoring is expensive and in our semi -arid climate and it is our opinion that a reasonable, statistically valid sampling program could not be carried out. Unlike most of the Portland, Oregon area, many of the drill holes and drywells constructed in Central Oregon were installed without any form of pretreatment. Not even a catch basin. In the Portland area many of the UIC systems were constructed with catch basins and sediment manholes preceding them. This may be because of the perceived need to remove gross sediments to prevent UIC failure in their less porous soils. In central Oregon many of the drill holes and drywells receive runoff directly through grate tops. By not having a minimum of sediment removal UICs, especially drill holes, are prone to failure. Rehabilitating a drill hole may be possible through drilling the hole deeper, but rehabilitating a plugged drywell, seepage pit or drainage gallery is next to impossible. The City of Portland has shown through statistically valid sampling and additional modeling that groundwater is being protected through the use of catch basins and sediment manholes prior to UIC injection. Because of the complications presented by verification, the need to protect UIC systems and the need to protect groundwater quality this report recommends that that Type C and Type D UICs identified in this assessment be upgraded to include a minimum level of structural BMPs (pretreatment) that will protect groundwater quality while preserving the integrity of the UIC system. Recommendations for improvements to Type C and D UICs are provided in the individual assessments in Appendix 2. Most contaminants of concern, specifically metals and hydrocarbons, are hydrophobic and will attach to fine sediments contained in stormwater runoff. In general the primary goal of pretreatment BMPs is the removal of sediments from the stormwater runoff before injection. Additional natural filtering of sediments can occur in sand, soil and sediment in the unsaturated zone beneath the UIC. If the unsaturated zone below the UICs is Tess than 10 - feet then biological degradation of organic compounds may occur in addition to filtering. If the UICs are located in highly fractured rock then the additional filtering and degradation may not occur. H 13 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT It is anticipated that UICs located within delineated 2 -yr TOT well protection areas will be subject to additional pollutant monitoring at injection sites, including fecal coliform. Typical sediment removal BMPs do not effectively remove fecal coliform. HWA recommends that UICs in parking lots or right-of-way located in a 2 -yr TOT employ basic sediment removal BMPs as a first step. If permit discharge limits cannot be met then catch basins and sediment manholes can be upgraded with filter media containing non -leaching biocides. Such media will require frequent maintenance and regular replacement, but it can be effective in reducing bacterial loading. Final recommendations for pre-treatment BMPs should be made once the permit maximum discharge limits (MDLs) are issued for each facility or UIC. The best option for UICs located in the 2 -yr TOT is to utilize non-LIIC infiltration systems with appropriate structural and non-structural BMPs. In addition to pre-treatment, structural and non-structural BMPs should be implemented through site-specific or area -specific stormwater management plans for all county UIC systems. These plans would implement site-specific or area -specific system controls that include the following where applicable: • Best management practices for pollution source control (both structural and non- structural). • Measures to prevent storm water drainage from areas where hazardous and toxic materials are used, handled or stored to the maximum extent possible (both structural and non-structural). • Spill prevention and countermeasure plan tailored for each site or area. • Maintenance plan and schedule, with frequency of maintenance activities, including visual inspections and physical maintenance. • Employee and public education plan. • Identification of personnel or contractors responsible for implementing individual plans. D. Need for Additional Information This phase of work was limited to inventory and preliminary assessments of UIC systems. HWA staff conducted facility site walks and visual inspections of observable drainage features were made. In some instances the county provided site construction plans to assist in the assessment. For registration purposes additional information was obtained from public databases. The site inspections did not include subsurface investigation and only included information about the systems that could be obtained by visual assessment from the ground surface. Those systems that could be readily accessed were opened, visually inspected and qualitative and quantitative data was gathered. Certain assumptions may have been made about select UIC systems that could not be verified visually. Additional site-specific information may be required to make recommendations to meet groundwater protection goals. Recommendations for additional information are discussed in the individual site UIC assessments in Appendix 2. HWA 14 DESCHUTES COUNTY UIC INVENTORY AND INITIAL ASSESSMENT Assumptions regarding implementation of structural and non-structural BMPs are based on the on discussions with the DEQ. HWA believes that under permit each site can be approached in a similar manner as would be required for rule authorization, however, with more flexibility than would be allowed under rule authorization. E. Capital Cost Estimates As part of this report HWA has made preliminary estimates of capital costs for implementing the structural and non-structural BMPs outlined above. The costs are very rough and are to be used for budgeting purposes only and may be revised as more detailed information is made available. At this time the approach in assessing the level of improvements necessary to permit county UIC systems is sufficient for capital planning, or master planning, purposes. The estimates provided may include engineering, construction and permitting and may be site-specific or system -wide. Site-specific estimates for each of the facilities can be found in the individual site assessments and are tabularized below. The basic elements for capital cost estimating include the following: Site Specific 1. Capital improvements for each site, including surveying,, engineering and construction 2. Permitting, including preparation of a stormwater management plans and/or closure plans where applicable 3. One time sampling and cleaning of existing UICs as needed for closure or installation of pretreatment BMPs Facility Name Warehouse/IT Building $23,700 Justice Building/Courthouse ---- DesCo Admin/Comm Dev $120,500 DesCo Services Bldg $140,600 Historical Society $39,700 Health & Human Serv. Bend $72,000 Public Safety Complex $260,400 Terrebonne & La Pine ROW $210,000 Fairgrounds $45,000 Becky Johnson Center $19,600 Total: $931,500 System Wide 1. Permit Application (see Exhibit 6) 2. UIC WPCP Permit negotiation, including template review and comments and final permit development Estimates for permit negotiation; facilities operation and maintenance; and, compliance verification and reporting are beyond the scope of this report. HWA 15 DESCHUTES COUNTY I.IIC INVENTORY AND INITIAL ASSESSMENT V. Next Steps A. WPCF Permit DEQ is expected to publish a LIIC WPCF template for public comment and review in the fall of 2009. Once the template is finalized the county will have to negotiate a permit with the DEQ. We recommend that county retain HWA to represent them at each of the phases of the permitting process to maintain continuity and to represent the county's best interests. B. Interim Operation and Maintenance of County Stormwater Systems Assess interim stormwater system operational and maintenance needs to maintain the integrity of existing stormwater systems, prevent localized flooding and protect water quality. This is prudent and any work done towards this end can be incorporated into the SWMP that will be required under permit. C. Prioritize Capital Improvement Needs WPCF permits are for ten years. The permits are structured in such a way that milestones must be met during the life of the permit. It can be expected that non -complaint systems will need to be upgraded within four CIP cycles. That is, capital improvements needed to meet water quality goals under permit will need to be completed in four CIP cycles, or approximately 5 years. D. Long Term Operational Cost Based on Permit Assess the annual costs for operating and maintaining the county's stormwater collection, treatment and disposal systems. 00000 16 .43 F O Z 0 co cc coO LL co ? tu Z f' a0 Q, Z ?� W 'z oZ reo O ZZ LL 0 Z W Z Hci N Z C.1W 7 0) c O c (a Deschutes County Facilities b. catch basin c. catch basin with filter insert (Krystar Flo -Guard Plus) o Z oe 1. A pO `:. A♦o ♦jOA ,r ♦ 'fi t, ,e, 4r aA,O vvO )./ too�A AG♦�O Aor ♦o ce � 4 (� '�A 'k k#4310 "*49 7tA 10 •'I O J�rr / • xmmm /`'A r0/ x rfst 4/AO //A `v % ei if �ID S 4 . O at 9 'Itsa o ie +tA a /b /0 A4 !/ EEE;:::E i 4 :0-reo � .0 4e /OAA/ AA , /A •)j / �°AToJAS°v A G/ ;3+% �J d'' /�%A 445> V �0 Soo O/ {%� A/1 A1- vg lone of 3 CB's located in loading dock area i ((same facility as above) CB filled w/ sed. d •� 3 a Parkin lot west of DesCo Services Bldg Parking lot west of DesCo Services Bldg f Secure lot north of DesCo Services Bldg 5" Dia DH (12' deep) overflow © -2.2 from RE I No inlet/outlet to DW _ t rn M 0 o Historical Society 2 -yr TOT 2 -yr TOT 2 -yr TOT 2 -yr TOT L 2 -yr TOT_ 2 -yr TOT 2 -yr TOT 12.8. 3.5_ 62. 5,000 a _ 13.51 3.51 90: 14,5001 c 13.3 3.5 1[ 1 8 a r13' 3.5 78T 6,300 a 14 3.5 136 10,900 c 10.9 3.5 136 10,900 c m V ooMriMoc c• m yet V e - m to V Oe to N r - CO tD O r ?1 0.4 a 15; 0.4 a 10.7 41 a 10.11 41 1 a CO .0 m V V lio ri tATM a) r C r r m.0.0 V .-117. r Vet 'e•- 115.145 .0 V Or .O.0 V co V O of CO V co er- CO m V V u7 00 .-(0 m m m CO m CO m m m m m m CO cam— m m m m CO m CO 't a't 't 't O. 't G. G. Q. m Q. 't G t. a 6. G. a a a C a a o, G. o. `C t a .)e - • 5,600 5,425. 1,325 5,6251 5,425i 1,300' 5,600 5 1 1,275, 5,225 4,6751 800' 5,300 4,7751 875 o O) tih V M lA 5,825 3,900 775 5,8501 3,925; 825 5,900; 3,9251 850 5,9251 3,9751 925 5,8001 4,1001 1,050 5,500 4,300 1,000 5,525 4,325 1,050 6,1251 3,600 525 5,9001 3,7501 575 5,6251 3,175' 700 5,7501 3,350 625 5,7251 3,400 650 5,6501 3,3751_ 700 5,6001 3,4001 7751 5,8751 3,6001 650 N 1. -or- co to 5,5001 3,8001 1,025 5,5001 3,9001 1,075 5,6251 3,9001 1,000 2,900 2,350 1,875 2,850 2,225 1,775 1 33� 0 0 0 33� 0 0 0 x 0 s3�3x 0 0 0 0 X x 33�3��3333�� 0 0 0 0 0 0 0 0 0 0 0 0 0 0 �3 O 0 44.06141 -121.3075 44.06101 -121.3077 44.06111 -121.3078 44.0612; -121.3077 44.0603 -121.3109 44.0603 -121.3105 44.06031 -121.3105 44.06101 -121.3094 44.06171-121.3100 44.0617' -121.3096' 44.0617 -121.30931 44.0617 -121.3089 44.06131 -121.3090 44.06071 -121.3097 44.06071 -121.3095 44.06251 -121.3084 44.0626 -121.3098 44.06221 -121.3104 44.0641' -121.3078 44.0635 -121.3084 44.0634 -121.3083 44.0635 -121.3080 44.06351-121.3078 44.06271 -121.3088 44.0624' -121.3089 44.0624 -121.3074 44.06221 -121.3074 44.06211 -121.3079 L44.0552: -121.3170 44.05521-121.3168 44.0551/_ -121.3172 Q _ p �Q 71 of vv•v Npg m - .(To)hfAODo) wooOe.a.o d at A LLf=UgNsNppsN V Eli 323? 232gvvv32 z/ y/) M �N MM op NN MMM CV y y i Historical Society no no I -21 use/IT Buildin 11888 - 1 I NM (0 0 om �- r !-- r rNM rt`N O) r 'Q r m V Of r r V O) r r rtes County AC 12623 - MMMMMM NNNNNN N N N N N N rtes County Se 11675 - 1? f 11675 - 2? V 1 i LO t0 N t() i t0 N OD 1 t0 11675 - 7? N CO 1 tDtntotDu7 0.. t0 �• 0 O) 1 P.- f`r- t0 <D r 1 1 A <O <O s` ¢ o ¢g¢ G ut), 22 C C C m0..0 -0.•N 0 Nn•0-0-0. 0-t.. t.. ON 3m VMH r NM Tr 41 OD t• 00 co OrNM r r r r It tOf0(.000)ON r r r r r N NM N N V(0 N N ( N DnN HWA PROJ. NO.: 040811A DW _ 6,225 10,250310,2507 pk j active f 10.8 4. . b I I Health and Human SRwices I -a ... I, MMMM PO?e-. e' N C .nO.as 1000 l+)N .� MN Mce) n •-• e= slotted lid in lawn, catch basin from pking area Terrebonne ROW 2 -yr TOT 2 -yr TOT cm ISO e m.0.n 03 0 _.�_ In sr 0 to M Nus e- m X10 Moi In as ca .1- 6 ci I- co 0 Oi m r ---- ... 10 in CM M r d v- Ci m 0.O M P. Ci 10 .__. M ip 0 m� us M 101, 0 O M Ci m a Y_. In In M M IO M03 0 e- 11.9 3.5 I a 22.4 0.5 a 20.8 0.5 a 2. 0.5. - a m U)Io N N m co 1CO e - e- co T 0o. 0 V Ili nN �OD O e - m• N O 1.- r_. O a - N N N N N N N N N N N N N N N N N W 01 N N N N t Ad 0 N a't 4! naao.n'C.an.aaaaa I. 1,250 3,200; 3,200 1,250 3,150 3,150 1,300 3,150 3,150 1,475, 3,325; 3,325 1,575 3,150 153 0 1,275' 2,800' 2,800 1,175 2,600 2,600 975: 2,4501 2,450 1 875, 2,325 2,325 775= 2,400 2,400 700 2,400 2,400 925 2,700 2,700 875 2,725 2,725 575, 2.525; 2.525 1,000 2,925 2,925 1,125 2,950 2,950 1,325 3,075 3,075 1,375 3,100 3,100 1,350 3,000 3,000 1,575 3,225 3,225 1,600 3,325 3,325 7 8,250 4,300 7 7,850 3,850 00004oa000a00000000000 �1.:: 144.1010 -121.30651 44.1009 -121.3056 44.1004 -121.3058 44.1001 -121.3058 44.0999 -121.305Y 44.0999; -121.3050 44.0988;-121.3050 44.09881-121.3063 44.0985 -121.3071 44.0987 -121.3078_ 44.0987 -121.3084 44.0991 -121.3083 44.09937 -121.3084,' 44.09951-121.3074 44.0997: -121.3074 44.099911 -121.3085 I 44.1000 -121.30681 44.0997 -121.30641 44.0996; -121.3057 1 44.0994 -121.3055 1 144.0992 -121.3057 11 44.0992 -121.3048 I 44.09951 -121.3046 1 44.3513 -121.18051 -� i rC� I 10209 - 2 na 11 44 3513; -121 17911 co W 0000 CCCCCCCCCCCCCCCCCCCCCC O 0.- h coQ) coN U) slotted slotted W N u) !71 N •a co 401 co 0) O) nine ROW 10209 - 1 1 Ina _ NCDO r e - ONM 1 1 1 1 V Of0 r 1111111.12 n c0 0) O e^ N N N N 0, N et N 0fon N N r N r 000000000000000000 .° t: 0 F. F+ oDCD M 01 00 d NM V V V V V V 10 t01 V -OD 0)O V V V V 4D T NM 0 0 T}In 0 0 ors 0 10 t0 ODC 0 U HWA PROJ. NO.: 040811A ate... xov tim o. a`0 0 4.a g e o of `� '`'�� yy \0 o0a' eco be ato a R` a O a �- Q 4,s$V5-1 ea X�ovs e O1ey�a ������ tye •• . Notes I Downtown La Pine ROW 1 N .0 0) C G i Ea 3 0 -e 2 m cu co Ea not previously inventoried (near downtown) c E Rock backfilled pond w/soil on top Rock backfilled pond w/soil on top Becky J Center (6" DH overflow at -1 RE) Icl m r-- QC co_Qp N I6.81 4j 1 14,200 a _ 6.71 41 1 10,200. a 1 m c5 CV h 7:. m m O7 CV h J. --T-- m O r r 1.7 0.5 11,070 a 1.3 0.51 18,4501 a 1.4. 0.51 36.9001 a 1 0.51 15,5801 a 1.3 0.51 42,2301 a 1.1 0.5; 13,3251 a 2.2i 0.5' 29,7251 a 2.2 0.5 14,3501 a 1.8 0.5 34,8501 a 1.7 0.51 8,200 a 1.6 0.5 38,950 a 5.2. 4. . a m 0 --------•-- r CO cs• CO c•-• CO M - 0 r 33333333 0 0 0 0 0 2 o o 2 r 33333333 2 o 3333 2 2 o 0 0 0 Q o Q o t'tl . 0. x'"_"x n o. r Y o. 925115,500 4,975 1,200, 16,100 5,650 1,075116,4001 5,7501 3,450 17,400 2,500 00ca C1•0c)cica001-F-I-I-I-F-h-F-F--/- 0 g' C 43.67461 -121.5041 1 43.67621 -121.5041 143.6747 -121.5006 43.6748 -121.5017 43.67551-121.5016 43.6758 -121.5011 43.6757 -121.5009 43.6752' -121.5043 43.6746 -121.5075 43.6716 -121.5053 43.6708; -121.4909 43.6709'-121.4955 43.6714 -121.4929 43.6714 -121.4954 43.67261 -121.4928 43.67261 -121.4946 43.6733; -121.4909 43.67381 -121.4911 43.67381 -121.4953 43.6740 -121.4809 43.6742 -121.4955 43.6693 -121.5055 44.23671 -121.1840 44.23471 -121.1852 44.23381 -121.1826 44.2348; -121.1814 • 12. mc)c)cloociol2mascomatmmmmcgas 10:D171,12 fA N CO N y v d C 0 (0 C C —p' C C C C C C C C C en a) E m CO 'fl 0) C C Becky Johnson Center I no 1 - 1 r slotted CO CAOQp CV CV CD r CD N. CD Ch CA CO CO N CV CV CV 0 CD CD CD r r r r r lW09-10 10209 - 11 10209 - 12 10209 -13 10209 -14 10209 - 15 10209 - 16 10209-17 10209 - 18 10209 - 19 10209 - 20 10209 - 21 10209 - 22 10209 - 23 10209 - 24 Y.rNO C 1 1 V )p �r C N 0 CO >. J HN 0) >. N 0 N 0 0 0) 0) 0) 0) >. >. 7..>1 >. H y CA u) 0) 01 N N co >1 >. >. >. >. a COCA CD 0) >. CA N CO CO 0) 0) 0 01 >. T >. >+ b y 6 CU 0 d >.›.• >. - V O O O :CCC OrNCe)�• CO CO CO t/) pr` CD CO CD CC) CO 02 Ch O e- CO CO t` r` N M N. r- d' 10 CO r• r- ti r- r• W CO CD r- r- Co Co r• CC)•• m Co 00